Aaron was convicted in 2005 of murdering Aaron Crawford based largely on the testimony of Daniel Wesley, who claimed he witnessed Aaron and a co-defendant firing guns during a gang-related shooting on May 7, 2002. Aaron received a 45-year sentence — 25 years for murder plus a 20-year firearm enhancement. But the case began to unravel when Wesley testified at the co-defendant's 2010 trial that his identification of Aaron was false and had been coerced by police.
The appeals court found that Wesley's recantation was supported by additional evidence that emerged after Aaron's trial. Wesley provided consistent statements to both defense counsel in 2017 and to Cook County State's Attorney investigators in 2018, maintaining that he 'did not see Chancellor Aaron shoot and kill Aaron Crawford.' As Justice Johnson wrote, 'Wesley was providing the same statement, no matter who was taking it down — that when the State sent two investigators to probe Wesley's statement, they received an affirmation of the statement provided to defense counsel.'
The court emphasized the weakness of the original evidence against Aaron, noting there was 'no confession and no physical evidence connecting defendant to the shooting.' The only other key witness, Karen Luckett, never claimed to see the actual shooting and gave conflicting statements about whether she saw Aaron with a gun. 'Calling Luckett an eyewitness would overstate her testimony,' Justice Johnson wrote. The court also noted that prosecutors twice refused to approve charges based on Luckett's identification alone.
Aaron's case reached the appellate level multiple times. After his initial conviction was upheld on direct appeal in 2009, the court in 2015 reversed the trial court's denial of his motion to file a successive post-conviction petition, finding Wesley's recantation presented 'a colorable claim of actual innocence.' Circuit Judge Mary Margaret Brosnahan presided over the original trial and subsequent post-conviction proceedings.
The State argued that Wesley and other defense witnesses who came forward were contacted by Aaron's brother, suggesting potential coordination. But the court found this argument unpersuasive given that Wesley had been 'subject to examination by the State multiple times, as well as to a more recent interrogation' by state investigators. The prosecution chose not to file a motion to dismiss Aaron's post-conviction petition and agreed to proceed to an evidentiary hearing.
The trial court's January 2024 denial of Aaron's petition contained a critical error, the appeals court found. Judge Brosnahan conflated Wesley's 2017 affidavit with a 2018 investigative report by state investigators, referring throughout her order to a nonexistent '2018 affidavit.' 'By conflating these two documents, the trial court failed to consider the totality of the evidence offered by defendant at the third stage evidentiary hearing,' Justice Johnson wrote.
Justice Wilson wrote a special concurrence addressing what he called 'a doctrinal ambiguity' about the proper standard of review when appellate courts consider post-conviction hearings based solely on documentary evidence rather than live testimony. He noted that while the outcome would be the same under either standard, the inconsistency 'could have real consequences for litigants and for the integrity of future postconviction proceedings.' Wilson warned that unclear standards might incentivize parties to manipulate the form of evidence to secure preferred appellate review.